Nine months after a League of California Cities report warned that pension costs were increasingly unsustainable, more than 100 local governments in the Golden State are asking voters for tax hikes on Nov. 6 – which Bond Buyer says is nearly double the record of 56 set in November 2016.

The Nov. 6 measures are on top of 36 city and county taxes that went before voters in the June 2018 primary.

Historically, local hikes in sales and hotel taxes are approved at least 60 percent of the time in California. They’re generally linked to a specific local need – not growing labor costs. With CalPERS’ bills to local governments on track to double from 2015 to 2025, such claims would seem dubious this election year.

Nevertheless – aware that voters likely would be cool to the idea of raising taxes to pay for pensions far more generous than those in the private sector – even now, many local elected leaders depict the hikes as necessary to pay for public safety or for fixing potholes and longer library hours.

Local officials assert hikes are about adding services

In the lead-up to the June primary, virtually the entire city leadership ranks in Chula Vista campaigned for a half-cent sales tax hike on the grounds that it was crucial to adding dozens of badly needed police officers and firefighters.

The tactic worked as Chula Vistans backed the increase. But city leaders’ claims of a coming public-safety hiring spree were impossible to square with the numbers from the city’s budget office. In April, it warned of “bleak” times ahead for San Diego County’s second-largest city, including an annual structural deficit that could reach $26.6 million by 2023 – with surging pension bills mostly to blame.

In Santa Ana, where voters are being asked to raise sales taxes by 1.5 percentage points on Nov. 6, the campaign for the tax hike rarely mentions pension costs.

But once again, a city bureaucrat framed the tax hike in more candid fashion.

“We’re not immune to the labor cost increases that are occurring throughout the state of California and throughout the country. We need to be able to provide additional services to the community. The question before the voters is what level of services do they want from their government?” Jorge Garcia, a top aide in the Santa Ana city manager’s office, told Bond Buyer.

Santa Ana’s pension bill is expected to go from $45.1 million in 2017-2018 to $81.2 million by 2022-2023 – an 80 percent increase.

‘The cause of this point-blank is CalPERS’

But some politicians have no patience with misleading narratives. “The cause of this point-blank is CalPERS and our pension fund,” Lodi Councilwoman JoAnne Mounce said in June when the Lodi City Council decided to put a half-cent sales tax on the Nov. 6 ballot.

As the League of California Cities reported in January, “With local pension costs outstripping revenue growth, many cites face difficult choices that will be compounded in the next recession. Under current law, cities have two choices – attempt to increase revenue or reduce services.”

The severity of the pension crisis is illustrated by the fact that it is sharply worsening in a period in which there is often seemingly good news on the fiscal front.

State revenue is expected to go up in 2018-19 for a 10th straight year.

County assessors report a 6.5 percent increase in property taxes this year. That’s triple the rate of inflation and comes even with Proposition 13 preventing increases of more than 2 percent on homes, businesses and other properties that didn’t change hands.

In July, CalPERS announced a second straight year of above-average earnings on its investment portfolio, which rose in value to $357 billion.

This prompted a news release from a top state union leader disputing talk of CalPERS’ poor health.

“While it’s important not to focus on one-year returns, these returns continue the long-term trend of CalPERS performing above or near its long-term discount rates and once again defying the sky-is-falling predictions of system critics,” wrote Dave Low, executive director of the California School Employees Association.

But despite the good returns, as of July, CalPERS only had 71 percent of funds needed to pay for its long-term financial liabilities, the Sacramento Bee reported. That’s far below the 80 percent funding level that is considered the absolute minimum for a healthy pension system.

The California Public Employees Retirement System and the California State Teachers Retirement System recently announced that they had exceeded their investment goals by at least 1 percentage point in fiscal 2017-18, with CalPERS citing annual gains of 8.6 percent and CalSTRS reporting 9 percent returns.

This came after strong returns in 2016-17 as well for both of the pension giants. But even with CalPERS now reporting $355 billion in assets and CalSTRS $225 billion, both systems have 70 percent or less of funds needed to cover their long-term commitments.

This troubling long-term picture is why the League of California Cities, in a January report, said it expects CalPERS to keep raising rates on local governments for years to come until they become “unsustainable.” CalSTRS, meanwhile, relies on the Legislature to set the rates it charges workers, districts and the state for pension costs – and the bailout the Legislature approved in 2014 that sharply increased what districts in particular must pay has not shored up the system nearly as much as was hoped.

Against this backdrop, CalPERS and CalSTRS are offering hints that they aren’t happy with the Legislature and think it is making their jobs more difficult.

CalSTRS’ chief investment officer, Christopher Ailman, issued a statement about the good returns that downplayed their significance: “We will rank high compared to similar funds, but it is only one year. We need to repeat that performance year in and year out, on average, over the next 30 years.”

But in an interview with the Private Equity International website that was posted July 2, Ailman elaborated on his view of investment gains. He did so in a way that challenged claims made by many Democratic lawmakers and pro-pension groups such as the Californians for Retirement Security that state pensions’ biggest problem was the Wall Street crash of a decade ago.

CalSTRS exec: Don’t blame investment results

“Ailman points out it’s often not the investment results that have led to the underfunding, it’s either poor management of liabilities or a lack of contributions,” the article said.

“Asked whether this keeps him up at night, he says he sleeps like a baby – wakes up and screams every three hours. ‘We pay out half a billion dollars a month in benefit payments, more than we bring in.’”

In the interview, Ailman also complained about Assembly Bill 2833, a state law that took effect last year that requires pension systems to disclose more information about expenses and fees related to their investments. He said the law ignored existing disclosure requirements and that it had caused CalSTRS to miss out on lucrative opportunities.

He said the “extra rules and extra issues” were having unintended but negative effects.

“We now have a situation in the state of California where CalPERS and CalSTRS have less invested in Silicon Valley than the Dutch, Asian and Middle Eastern sovereign wealth funds. Fundamentally, as a native Californian I think that’s just so wrong, but I can’t change people’s minds. It is what it is now,” Ailman told Private Equity International.

CalPERS knocks bill to monitor divestment laws

CalPERS’ concerns about legislative actions are also plain, if more muted. The Pensions & Investments website reported July 18 that the pension fund opposes Senate Bill 783, which already passed the Senate and now is before the Assembly. It would set up a review body to analyze how CalPERS and CalSTRS had complied with state laws directing the pension funds to divest from certain industries. CalPERS says this review panel would duplicate the work of pension staffers.

Given that CalPERS and CalSTRS at times have resisted the Legislature’s attempts to micromanage their portfolios, SB783 could be seen as giving teeth to lawmakers’ attempts to have a bigger say in investments.

The debate over SB783 comes as CalSTRS faces demands from activists to divest in a new corner of the private sector: companies which run private prisons. Other recent calls for divestment have targeted assault-rifle makers; finance companies that helped with construction of the Dakota Access Pipeline; and fossil-fuel companies.

At fault was a drafting error in a key piece of legislation designed to bring uniformity and predictability to the state’s pot regulatory structure, with the possible legalization of the drug around the electoral corner. “California’s new medical marijuana laws were supposed to provide more structure and clarity for the state’s loosely regulated, billion-dollar industry, but in the past few weeks, dozens of municipalities have ignored that intention by moving quickly to ban delivery and other activities codified by the legislation,” the San Francisco Chronicle noted.

Moving too quickly at the tail end of Sacramento’s fall session, lawmakers passed a law “that imposed a deadline of March 1 for local governments to adopt land-use regulations for marijuana cultivation,” as the Sacramento Business Journal noted. “Under the law as adopted, those governments that miss the deadline would turn that authority over to the state.”

Domino effect

That triggered a rush to codify cities’ own regulations. In an abundance of caution, although the League of California Cities became aware that lawmakers decided they goofed, it “is advising cities without regulations already in place to quickly pass complete bans on cultivation to assert their authority over the state,” according to the Los Angeles Times. “Cities would retain the latitude to soften cultivation rules later,” the paper noted, adding that in San Diego, city officials are contemplating a moratorium rather than an outright ban.

In response to the unwelcome surprise, legislators have switched into high gear to reverse the trend. “The law’s authors are now scrambling to pass Assembly Bill 21, a bill that would eliminate the deadline and give local governments more time,” the Journal reported. Co-author Assemblyman Rob Bonta, D-Alameda, said municipal governments won’t face any pressure to slap on a ban by the first of March.

Gov. Brown promptly threw his weight behind the effort as well. “The governor supports allowing local municipalities a reasonable amount of time to come up with regulations that work for their communities,” Deborah Hoffman, his deputy press secretary, explained via email, according to the Journal.

A unified front

At the same time, the march toward marijuana legalization has advanced apace. “California’s legislative analyst and finance director estimate that legalizing marijuana for recreational use could net as much as $1 billion in new tax revenue for the state and local governments,” the Associated Press reported. “Finance Director Michael Cohen and Legislative Analyst Mac Taylor produced the estimate based on the provisions of the leading pot legalization initiative proposed for the November ballot.”

That effort, backed by Silicon Valley heavyweight Sean Parker, has managed to sideline the state’s other major initiative. ReformCA has yet to officially endorse the Adult Use of Marijuana Act, which Parker and Lt. Gov. Gavin Newsom have supported. “But last month a majority of its board members voted to suspend the ReformCA initiative,” as the LA Weekly observed; “the suspension of ReformCA’s own effort means, essentially, there is one initiative that appears to have the cash and organization to make it to the ballot in 2016.”

Fresh embarrassment

California recently suffered a new setback at the intersection of law enforcement and marijuana regulation. “Dozens of drug cases in Yuba and Sutter counties may be irreparably tainted and facing dismissal after a narcotics strike team officer and two associates were arrested on charges of transporting 247 pounds of marijuana to Pennsylvania,” the Sacramento Bee reported, referring to officers based in California. Sacramento attorney George Mull told the Bee, “Heath’s arrest stokes long-held suspicions in the cannabis community about rogue cops stealing pot in ‘smash and grab’ raids on growers. ‘Perhaps some law enforcement officers are seizing cannabis not because they see it as a violation of law but to seize a valuable crop for their own benefit,’ Mull said.”

Concentrated support

His initiative, which counts Lt. Gov. Gavin Newsom among its supporters, brought on the Coalition for Cannabis Policy Reform. “Coalition board member Antonio Gonzalez, who is also president of the Latino Voters League, said the coalition withdrew its rival initiative after Parker’s measure was modified to protect children, workers and small businesses,” Reuters reported.

“In California, amendments filed this week to Parker’s proposal would allow local governments a greater say in where marijuana can be sold, toughen protections for children, including a ban on marketing to minors and explicit warning labels on marijuana products, and require safety standards and enforcement of labor laws for people who work in the industry.”

In another victory for the Newsom-Parker proposal, some of California’s so-called “legacy activists,” among California’s early major medical marijuana players, threw their support behind the effort. “The members include Richard Lee, the founder of Oaksterdam University in Oakland and proponent of 2010’s unsuccessful Proposition 19 legalization effort; Neill Franklin, executive director of Law Enforcement Against Prohibition; Stacia Cosner, deputy director for Students for Sensible Drug Policy; Nate Bradley, executive director of the California Cannabis Industry Association; and David Bronner of Dr. Bronner’s Magic Soaps, a top-selling brand of natural soaps,” noted the Sacramento Bee.

Activists have nursed concerns that big corporate interests, backed by regulators, could swoop in and squeeze them out of the medical pot industry. “[G]rowers and marketers on the pot-rich North Coast are waiting to see how much the massive regulatory structure will cost them and whether to stick instead with the prosperous but risky outlaw status they have lived with for nearly two decades,” as the Press Democrat recently observed.

Bracing for change

The prospect of statewide legalization has also accelerated the push in some municipalities for fresh local restrictions. Input has been sought from law enforcement in states where marijuana decriminalization has already had time to take effect. After a recent visit to Colorado, where “law-enforcement groups such as the Rocky Mountain High Intensity Drug Trafficking Area continue to portray the situation in sky-is-falling terms,” officials from the City of Indio drew up an ordinance, ready for a vote in January, that would ban medical marijuana cultivation, according to Westword. “While medical marijuana has been legal in California since 1996, not every city allows cultivation and/or dispensaries that would sell it,” as the Desert Sun noted.

In fact, with a raft of new state laws aiming to bring marijuana fully within officials’ regulatory reach, the League of California Cities has set forth new guidelines for cities “within their legal rights to enact total bans on medical cannabis cultivation,” according to Cannabis Now. “Citing a 2014 case in which the California Supreme Court upheld a decision to permit local cities and counties to ban personal cultivation, Maral v. Live Oak, the organization reiterates that these bans can prevent the cultivation of small amounts of medical marijuana for personal use by qualified patients.”

At the same time, officials have begun eyeing new technology that would enable law enforcement to crack down on impaired driving. In conjunction with UC Berkeley researchers, Oakland outfit Hound Labs has begun work on a breathalyzer that detects marijuana, according to Inquisitr. “Initially the new handheld marijuana breathalyzer device will be tested by law enforcement agencies in the San Francisco Bay area and Lynn says depending on the results, will eventually be used across the country,” the site noted.

Residents of Los Angeles know that “medical” marijuana shops are not the only gray-market business that’s experienced a recent boom. In a city with a taste for pleasure and an enterprising working class, “massage” parlors are apt to have a significant presence — and L.A. is no exception.

To an even greater degree than pot shops, massage parlors offer policymakers a challenge: how to let legitimate legal businesses flourish, without also turning a blind eye to the unlicensed and unregulated sale of sexual encounters. Statewide, the issue is receiving renewed attention, thanks to the expiration this year of a 2008 law intended to solve the puzzle.

As Californians consider how to move forward, they’re coming to realize just how inadequate and ineffective the expired rules quickly became. Even more important, however, is that they — and all Americans — grasp why the ’08 law failed. Though massage law may not strike most people as a perfect example of the perils of bad governance, California’s return to the regulatory drawing board reveals that it is.

As The Sacramento Bee reports, the League of California Cities is pushing Sacramento lawmakers to return to an approach the 2008 law rejected — one in which local regulators had the authority to apply their own varying ordinances to the massage parlor business. Frustrated municipalities “say the 2008 law has left them ill-equipped to handle” the spread of massage parlors that’s growing across the state.

Failure of universal standards was predictable

How did the soon-to-expire law fail so badly to meet expectations? The answer closely fits a pattern that critics of bad legislation have long argued against. Especially in California, policymakers’ conventional wisdom adopts the same posture to any regulatory opportunity: first, sweep in with new, universal standards; second, create a new official body given full control over their enforcement and administration. Then, the logic goes, policymakers can sit back and watch the new regime efficiently work its magic.

With the massage industry, as any other, the result of this kind of policymaking is decidedly less than magical. To be sure, it works like a charm — just not in the virtuous way legislators had hoped.

Policymaking at the national level shows time and again how big business interests in any industry lobby hard to secure and protect centralized regulatory standards, which are easier to navigate, “capture,” and, in some circumstances, work around. As is now par for the legislative course, California’s massage industry came out strongly in favor of universal rules controlled by a single government entity. Sure enough, under the 2008 law, local ordinances were replaced by a “state nonprofit” called the California Massage Therapy Council, which oversaw workers’ education, screening and certification.

But instead of ushering in a new era of clear, strong and judicious enforcement, the rules laid down by the 2008 law favored the massage industry. On the one hand, standardized permitting helps prevent rogue masseurs or masseuses from skipping from one town to the next. On the other, since the permitting system applies to individual workers, parlor proprietors who violate the law can repeatedly avoid punishment.

Massage parlors not like other businesses

The current law’s taste for uniformity, meanwhile, has stuck localities with a mandate to treat massage parlors the same way as any other businesses, despite the fact that so few other businesses are breeding grounds for illegal sexual commerce. That helps violators continue the very kinds of practices that centrally enforced standards were supposed to do away with.

That’s why California cities like San Gabriel are already getting started on new municipal regulations that would replace the misbegotten statewide regime.

Of course, if cities and counties manage to wrest regulatory control back from Sacramento, controversy is inevitable. There will always be some activists for whom a city may come down too hard or too soft on massage parlors. For a few, the ultimate solution to the challenge is to legalize prostitution.

In the meanwhile, however, California’s circuitous path back to diversity in local regulation has plenty to teach Americans about the limitations of standardized, top-down regulations. From Oregon to Ohio, massage law is making headlines. In an era when the Internet is creating a new realm of possibility for consensual sexual transactions, the use and abuse of massage parlors is a case study in the false promise of laws forged by big industries and big-government regulators.

I’m still giddy after the California Supreme Court ruled last month that the state had every right to shut down those noxious enemies of property rights and fiscal responsibility — redevelopment agencies. Better yet, the state’s high court ruled that another law that allowed those agencies to come back into existence was unconstitutional.

As of February, anyway, redevelopment is dead in California, the victim of an absurdly arrogant legal and political strategy pursued by redevelopment’s chief defenders. This is wonderful news, made even better by the teeth-gnashing of public officials who have routinely abused their powers under redevelopment law. Cry me a river.

But before I gloat too much, we need to remember that this victory already resembles one of those cheap horror movies where the Evil Thing has been vanquished, and all appears well, then its hand pokes out from the grave just as the credits begin.

No one gives up riches and power without a fight, so redevelopment lobbyists already are crafting new legislation to replace the dead agencies with new, revised versions. (Meanwhile, successor agencies will pay off old debt, and old projects will go on to completion. Many of those projects and property transfers slapped together after the law killing redevelopment agencies, or RDAs, was passed will be audited by the state controller, stopped or tied up in litigation. Many RDA officials, thankfully, will be out of work.) The fight goes on but I never would have expected such progress.

One of my earliest memories as a newly hired editorialist at the Register in the late 1990s was meeting with local property-rights activists in a parking lot outside a subsidized shopping mall project and looking at their charts explaining why a process called “redevelopment” was such a problem. As we gawked at the fruits of redevelopment’s corporate welfare, they explained how these urban-renewal agencies float debt without accountability and routinely misuse eminent domain, government’s power to seize private property for supposedly public purposes.

Days of Despair

As I plunged deeply into the issue, I never forgot that sense of near-hopelessness I felt in that parking lot. I never forgot the despair I saw on the faces of homeowners in Garden Grove as they begged the city to scotch a quietly hatched plan that would have driven them out of their middle-class neighborhood so that the city could market the land to a theme-park developer that was yet to be determined.

Over the years, I’ve interviewed victims of eminent domain, many of them immigrant small-business owners who couldn’t believe what was happening to them in America. They were bullied, put out of business and forced to spend years battling City Hall rather than building a better life.

The general public learned of the injustices after the U.S. Supreme Court’s 2005 decision in Kelo vs. City of New London, in Connecticut, which upheld the “right” of governments to use eminent domain for redevelopment-type economic projects. The grand revitalization project that destroyed homeowner Susette Kelo’s Connecticut neighborhood was abandoned, and the site remains a dumping ground. It serves as a reminder that officials in the United States can’t plan an economy any better than their equivalents in the old Soviet empire. Free markets work better than bureaucratic central planning.

I’ve seen how the redevelopment process has distorted economic markets and made it more difficult for people without political connections to build their businesses and their dreams. Redevelopment embodies crony capitalism, but there’s so much money in it, with so many consultants and politicians who benefit from it, that I never dreamed of the day when it could actually go away. Who would have thought that redevelopment agencies would be the ones on the outside looking in, scheming for new ways to regain some power and privilege?

Redevelopment officials are so used to getting their way with average citizens that they figured it would be no problem giving state elected officials the back of their hand. The seeds of their demise were sown after former Gov. Arnold Schwarzenegger attempted to divert some of their funds to fill part the perpetual state budget hole.

Diversion Scheme

Redevelopment — which morphed decades ago from a mechanism to fight urban blight into a scheme to divert county and state taxes to cities — is a creation of the state, so the governor argued that the state had the right to take some money. The League of California Cities and the California Redevelopment Association struck back with Proposition 22, approved by voters in November 2010, which forbade state diversions of redevelopment funds. It was sold to the public as a means to stop Sacramento politicians’ raids on local road funds.

The blight barons were gloating after their big victory, but then Gov. Jerry Brown came up with a work-around. He signed a law that shut down RDAs. After all, Prop. 22 can’t stop a raid on funds of agencies that no longer exist. And then he also signed a law that allowed the agencies to come back to power after paying funds to the state.

The redevelopment community challenged both laws and was pleased when the high court agreed to review them. But redevelopment advocates were stunned by the unanimous ruling that found that the Legislature was perfectly within its authority to abolish agencies that it had created. The justices also ruled 6-1 that agencies cannot buy their way back into existence because that violates Prop. 22, the very initiative the RDAs had crafted. How sweet is that reasoning?

I celebrated one recent night at philanthropist Moe Mohanna’s downtown Sacramento Oddfellows building. Many in this odd group of activists on the left and right, including Mohanna, had been abused by redevelopment agencies. We ate Persian food and savored the rare victory for the good guys. But we realized that redevelopment is, as the Monty Python troupe once said, “not quite dead.”

Let’s hope coalitions emerge this year to keep this Evil Thing in its grave.

— Steven Greenhut

JAN. 6, 2012

By STEVEN GREENHUT

On December 29, 2011, the California Supreme Court handed down what the state’s urban redevelopment agencies (RDAs) and their supporters called a “worst of all worlds” ruling—first upholding a law that eliminates the agencies, then striking down a second law that would have allowed them to buy their way back into power. This was great news for critics who had spent years calling attention to the ways modern urban-renewal projects distorted city land-use decisions, abused eminent-domain policies, and diverted about 12 percent of the state budget from traditional public services to subsidies for developers, who would build tax-producing shopping centers and other projects sought by city bureaucrats. As of now, the agencies are history, though the redevelopment industry is working to craft new legislation that would resurrect them in some limited form.

California’s redevelopment agencies were first introduced in the 1940s to combat blighted urban areas by providing a tax-sequestering mechanism so that cities could concentrate investment in struggling areas. But after Proposition 13 placed limits on local property taxes and various ballot initiatives further constrained the way state and local governments could spend their revenues, redevelopment mutated into a tool for tax-hungry cities to capture dollars that would otherwise go to counties and the state. Restoring decrepit areas took a back seat to grabbing revenue. The RDAs loved to oversee the construction of shopping centers and auto malls, for example, because those projects generally filled city coffers with sales taxes.

No Money

As California faced a protracted structural budget deficit, however, there were fewer and fewer pots of money for officials to plunder. Though operated by cities, RDAs are actually state agencies. In 2009, Governor Arnold Schwarzenegger tried to “raid” redevelopment funds, but the powerful League of California Cities and the California Redevelopment Association (CRA) struck back in 2010 with Proposition 22. This ballot initiative, sold to voters as a means to keep Sacramento politicians away from local transportation budgets, forbade the state from taking RDA funds. After its passage, the measure’s advocates viewed redevelopment funds as sacrosanct.

In fact, Proposition 22 planted the seeds of redevelopment’s demise. Since the agencies’ money was now off limits, new Gov. Jerry Brown decided simply to shut them down. Yet as a sop to the legislature’s many redevelopment supporters—especially in the Democratic Party—the governor also signed another bill that let the agencies stay in existence by paying what the League and the CRA called “ransom.” Redevelopment critics were happy when the governor signed the first bill, but dismayed when the second enabled many of the biggest and most abusive agencies to remain alive by spending tax dollars.

Redevelopment officials, for their part, weren’t happy with any funding loss and filed a lawsuit challenging both laws. This was a controversial strategy—and proved a devastating mistake. “We’re very gratified that the California Supreme Court has agreed to take our case, issued the stay we requested to preserve the status quo, and that it is moving forward on an expedited basis,” the League of California Cities’ executive director, Chris McKenzie, wrote in August. But McKenzie failed to see the strategy’s perils, which other redevelopment boosters, such as state Senator Bob Huff, R-Diamond Bar, had warned about.

‘Proper Exercise’

The court ruled 7–0 on the first bill that ending the agencies was “a proper exercise of the legislative power vested in the Legislature by the state Constitution. That power includes the authority to create entities, such as redevelopment agencies, to carry out the state’s ends and the corollary power to dissolve those same entities when the Legislature deems it necessary and proper.” Then the court ruled 6–1 that the second measure was unconstitutional: “A different conclusion is required with respect to Assembly Bill 1X 27, the measure conditioning further redevelopment agency operations on additional payments by an agency’s community sponsors to state funds benefiting schools and special districts. Proposition 22 . . . expressly forbids the Legislature from requiring such payments.” For critics of the RDAs, using Prop. 22 to deliver redevelopment’s final blow was the sweetest part of the ruling.

The redevelopment agencies are fighting to return, but unlike last year, when most Republicans opposed the effort to dissolve the agencies, 2012 may see a minority party doing the right thing. A number of assembly Republicans who refused to support Brown’s anti-RDA legislation claimed that they did so because the package of bills would just resuscitate the RDAs. Well, the state supreme court has now killed that argument. Will Republicans side with property rights and limited government at the local level, or again stand up for these misguided and destructive bureaucratic bodies?